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:)5/20/2010 THu 14: 01 FAX 612 696 5163 2002/010 <br /> 0 <br /> TARGET. <br /> May 18, 2010 <br /> Michelle Henry,Registered Environmental Health Specialist <br /> County of San Joaquin <br /> Department of Environmental Health <br /> 600 E. Main St. <br /> Stockton,CA 95202 <br /> Re: Facility Certification of Return to Compliance <br /> Target Store T0738 Tracy, CA <br /> Dear Ms. Henry: <br /> This letter responds to the inspection conducted at Target Corporation's("Target")above-mentioned store <br /> (T0738)on March 12,2010_ This response is intended to meet your requests to the best of our ability. <br /> We expressly assert and reserve without waiver all of Target's rights and defenses in this matter. <br /> Violation#20 66262_34(f)CCR <br /> Environmentally-Sensitive Items Management("ESIM") Storage Area <br /> Target's container labels are designed to provide all of the information required by 22 C.C.R. <br /> 66262.340. That section states that the labels shall contain the"composition and physical state of the <br /> wastes." 22 C_C.R. 66262.34(f)(3)(A). This process ensures that chemicals that may negatively react with <br /> one another are stored separately and meets the goals of the labeling requirements. In addition,based on <br /> Target's understanding, further information as to the products' "contents" is not required on the container <br /> labels by the regulations, in part because that information may be found on the individual product's label <br /> itself. Moreover, because of the many types of products sold in Target stores, it would be impractical and <br /> burdensome to list the contents of each individual product on the containers' labels. <br /> Near Compactor <br /> The sorting cart is not a"container"for waste accumulation. The products are placed in the cart for <br /> transport to the Backroom/Receiving for processing by the Reverse Logistics Specialist. The point of <br /> waste generation is the Reverse Logistics Specialist who will decide whether the unsalable product can be <br /> donated or whether it must be processed through ESIM. Because the sorting cart is not a"container"for <br /> waste accumulations under the regulations, the labeling requirements do not apply. <br /> Pharmacy <br /> Target incorporates by reference its explanation above regarding the ESIM Storage Area_ Additionally, <br /> the pharmacy label provides hazard information through the associated waste codes. <br /> I <br /> Violation 452 66262.34(d)(2)CCR <br /> Emergency coordinator infori ation is kept on every"Alert One Flipchart."The flipchart is posted by <br /> phones and lists the 24-hourTarget emergency dispatch line,Alert One. The tlipchart also lists the Leader <br /> on Duty("LOD")as emergency coordinator. The LOD is the active Target emergency coordinator and is <br /> available by internal intercom. San Joaquin County Environmental Health has approved this protocol for <br /> emergency coordinators in Target's Hazardous Materials Business Plan. <br /> Violation #24 66265.17 CCR <br /> Store team members utilize Target's Smart Sort system for returned,damaged,or defective products_ <br /> Smart Sort prints a sticker that identifies the proper ESIM container for each product(e-g.,"FU <br /> indicating"flammable"for most aerosol cans). The ESIM 1 chem ictal reference posters in Reverse <br /> Corporate Risk and Responsibility, 1000 Nicollet Mall, TPS-2074, Minneapolis, MN 55403 <br />